Agence du revenu du Québec v. Custeau, 2020 QCCA 1496

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Summaries

Summary Under

s. 248(10) “in contemplation of” test appropriately applied only on a forward-looking basis where the historical transaction was purely commercial

When a family small business corporation (the “Corporation”) was in financial difficulty, a Quebec regional development fund and affiliated...

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Summary Under

no avoidance transaction where subsequent utilization of PUC created with PUC-averaging was not contemplated

When a family small business corporation (the “Corporation”) was in financial difficulty, two Quebec regional development funds agreed in 1997...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.